The Public Company Accounting Oversight Board is rolling out a new series of staff publications targeted at auditors of small public companies, starting with one on critical audit matters, as board members face the likelihood of a deregulatory emphasis under the incoming Trump administration and probable changes in board composition.
The PCAOB released the first of the new series of staff publications, “Audit Focus: Critical Audit Matters,” which aims to provide easy-to-digest information to auditors, especially those who audit smaller public companies. With an eye toward protecting investors and improving audit quality, each edition of Audit Focus reiterates applicable auditing standards and staff guidance and offers reminders and good practices tailored to PCAOB-registered auditors of smaller public companies.
The PCAOB staff is continuing to identify a great many deficiencies related to critical audit matters. CAMs are a relatively new requirement from the PCAOB. A CAM is defined as any matter arising from the audit of the financial statements that was communicated or required to be communicated to the audit committee and that relates to accounts or disclosures that are material to the financial statements; and involved especially challenging, subjective or complex auditor judgment.
This edition of Audit Focus highlights key reminders on determination, communication and documentation of CAMs, along with the PCAOB staff’s perspectives on some of the common deficiencies, such as not accurately describing how a CAM was addressed in the audit, plus good practices that the staff has observed related to CAMs, such as use of practice aids.
PCAOB board members George Botic and Christina Ho discussed the recent inspection findings during a panel discussion Wednesday during Financial Executives International’s Current Financial Reporting Insights conference.
“When you think about where our inspectors see repeated observations, deficiencies, if you will, particularly in Part I.A, which are for the firms not obtaining sufficient appropriate audit evidence, things like revenue recognition, inventory, allowance for credit losses in the financial sector, areas around business combinations, allowance for allocation of purchase price, things such as that, as well as long-lived assets, goodwill, intangibles, evaluation, those are some of the more frequent areas,” said Botic. “ICFR certainly is one as well in the internal control space. But those areas, those themes, really haven’t changed. Sometimes we’ll see more of one versus another.”
During its inspections last year, the PCAOB saw some improvements at the largest firms, even though audit deficiency rates still appear to be high, with 46% of the engagements reviewed in 2023 having at least one deficiency significant enough to be included in Part I.A of the inspection report, excluding broker-dealer audit inspections, according to a staff spotlight publication that was released in August.
“There appears to be some improvement in terms of the deficiency rate trend for the largest firms,” said Ho. “It’s probably too soon to tell whether that is going to be the ongoing trend. Also for triennial firms, the spotlight also highlighted the fact that the deficiency rates are not improving.”
She pointed out that financial restatements are another way to look at the situation. “Obviously, the deficiency rate is not the only measurement of audit quality,” said Ho. “We also look at restatements, which I think for many of the preparers and audit committees that I talk to, and even investors, they focus on that metric a lot. The multiple metrics paint a picture.”
PCAOB board member Christina Ho speaking at the FEI CFRI virtual conference
Botic sees advantages in having several such metrics. “The audit process is one of the most complex processes, probably in business,” said Botic. “When you think about all the judgments that you all go through for your financial statements and preparing them, then the auditor makes his or her own risk assessment judgments, it’s an incredibly complex process. So I agree, not one metric necessarily is the only metric for sure. We’re inspecting the audit, so our inspectors are looking at what the auditor did or didn’t do, as the case may be, and as part of that, we may identify the accounting was wrong. That is one possibility, as Christina mentioned, the categorization of the reports. But in my view and from my prior life as well, and spending a lot of time in inspections, I actually think that the spread from the inspection deficiency rates for the filers that we looked at compared to the restatement number, I think that’s actually … reflective of the success of our inspection program.”
Ho recently found herself singled out in a letter from a pair of Senate Democrats, Elizabeth Warren of Massachusetts and Sheldon Whitehouse of Rhode Island, for painting an overly rosy picture of the problems plaguing auditing firms, and she complained in a LinkedIn post that they were “persecuting” her and trying to “stifle” her from “expressing views inconsistent with their false narrative.”
Accounting Today asked Ho during a press conference after the FEI CFRI session about the political pressure she faced, especially with President-elect Trump’s administration coming in and perhaps replacing PCAOB board members as happened during his first administration as well as the Biden administration.
“Like I said in my LinkedIn post, I’m not a political person,” Ho responded. “When I was at Treasury, I worked under two different administrations as a career person, and I always feel like accounting shouldn’t be political. But obviously, elections have consequences, and I’m not living in a cocoon that I’m not aware of what’s going on. I really do think that it’s in the best interest of the capital markets for political influence to be minimized to technical areas that require expertise, and that’s how I operate, whether I was in Treasury or even at the board here. I often feel like the areas we work in, auditing and accounting, are specialized and require expertise and I hope that the experts can always be allowed to voice their views and also do their job well.”
The PCAOB has been facing pushback on some of its proposed standards, such as the so-called NOCLAR standard on the auditor’s responsibility to detect noncompliance with laws and regulations, as well as proposed standards on firm and engagement metrics. The Securities and Exchange Commission has already approved and adopted one of the PCAOB’s more far-reaching standards, on a firm’s quality control system, Ho pointed out. However, she recognizes the criticisms that the PCAOB has been hearing about some of the other proposed standards, even though NOCLAR and the other standards are still scheduled on the agenda this year.
“One of the really important things that regulators should do is to listen,” said Ho. “We should take comments very seriously and we should not rush into adopting standards or rules when we don’t have enough evidence to support the benefits and also the effectiveness of those proposals.”
She acknowledged that the increased risks and responsibilities of auditors, as well as the potential penalties, may be one factor that’s making it harder to attract young people to the accounting and auditing profession.
“I have certainly heard many anecdotal comments about the regulatory environment making the profession less attractive,” said Ho. “I’ve heard from people who talk about how they don’t want to do public company audits because of the inspections, and also our posture on enforcement. If you are not allowed to get indemnified, you know, as an individual, if something happened and there’s in your sanction, certainly people consider that as an increased risk for what they do. I think these things have an impact on the attractiveness of the profession and certainly impact talent. That is some of the anecdotal information I’ve heard. I’ve also heard from smaller firms that they are trying to stay under the 100 number because that will move them into annually, inspected so that they can stay under 100 so they don’t have to be inspected every year. Those kind of comments certainly concern me, because I don’t think this audit marketplace can afford less competition and also less talent. These are things that I think about and I’m concerned about.”
The PCAOB typically inspects each firm either annually or triennially (i.e., once every three years). If a firm provides audit opinions for more than 100 issuers, the PCAOB inspects them annually. If a firm provides audit opinions for 100 or fewer issuers, the PCAOB, in general, inspects them at least every three years.
Ho was also asked about the PCAOB’s relationship with the Institute of Internal Auditors after the two organizations clashed over the PCAOB’s exposure draft for its audit confirmation standard initially seemed to blame internal auditors before it was revised following a protest by the IIA. Ho met with the IIA and established a better understanding.
“I have a good relationship with the IIA organization, and I actually have been an internal auditor before,” said Ho. “I understand what they do and their values and why it’s important. I certainly think that they play a key role in fostering the trust of the capital markets, because they are in the company. Different data that have been published that the external auditor, they come in and focus on the financial statements and the internal control over financial reporting. Their scope is limited to that, whereas the internal auditors are covering the entire company and the operations and and they have access to much more information and people than external auditors, so they play a key role in facilitating the trust. It looks like they are also focusing a lot on modernizing their standards. They have done that, and then they have been really focusing on AI as well. So I think that it’s important to make sure that all the key players in the financial report ecosystem are working together so that we can collectively ensure the quality of the financial reporting and the audit.”
Accounting Today also asked about the role of artificial intelligence and data analytics programs in auditing and if they could be degrading audit quality without the human element being present.
Ho pointed out that the PCAOB has published a staff spotlight report on generative AI. “What the staff is seeing from the firms and the issuers in terms of their use of AI, based on that, it’s pretty clear, and based on my understanding, too, that the use of AI in the audit and financial reporting is still very much focused on repetitive tasks and very low-level areas that do not involve human judgment,” she added. “And everything they were doing using AI still requires human supervision. At this point, I don’t see right now that AI is off doing its own thing. I know that the firms are making significant investments, and AI is evolving, and more and more companies are using them. There will be more maturity. And I think that there is an opportunity, which is why it’s very important for regulators to stay on top of that, to make sure that we’re proactive in thinking and to ensure that we put guardrails if needed to make sure that there is a responsible use of AI, but at the same time, not keep people from using technology to make audits more effective and efficient.”
The Internal Revenue Service issued a notice Friday giving some breathing room to participants and advisors involved with micro-captive insurance companies.
In January, the IRS issued final regulations designating micro-captive transactions as “listed transactions” and “transactions of interest,” akin to tax shelters. The IRS had proposed the regulations in 2023 but needed to be careful to comply with the Administrative Procedure Act to allow for a comment period and hearing after a 2021 ruling by the Supreme Court in favor of a micro-captive company called CIC Services because the IRS hadn’t followed those procedures back in 2016 when designating micro-captives as transactions of interest. However, the micro-captive insurance industry has asked for more time to comply with the new reporting and disclosure requirements, and one group known as the 831(b) Institute announced earlier this week it had sent a letter to the IRS’s acting commissioner requesting an extension.
On Friday, the IRS issued Notice 2025-24, which provides relief from penalties under Section 6707A(a) and 6707(a) of the Tax Code for participants in and material advisors to micro-captive reportable transactions for disclosure statements required to be filed with the Office of Tax Shelter Analysis. However, the relief applies only if the required disclosure statements are filed with that office by July 31, 2025.
In the notice, the IRS acknowledged that stakeholders had raised concerns regarding the ability of micro-captive reportable transaction participants to comply in a timely way with their initial filing obligations with respect to “Later Identified Micro-captive Listed Transactions” and “Later Identified Microcaptive Transactions of Interest.”
In light of the potential challenges associated with preparing disclosure statements during tax season and in the interest of sound tax administration, the IRS said it would waive the penalties under Section 6707A(a) with respect to Later Identified Micro-captive Listed Transaction and Later Identified Microcaptive Transaction of Interest disclosure statements completed in accordance with Section 1.6011-4(d) and the instructions for Form 8886, Reportable Transaction Disclosure Statement, if the participant files the required disclosure statement with OTSA by July 31, 2025.
The relief is limited to Later Identified Micro-captive Listed Transactions and Later Identified Micro-captive Transactions of Interest. However, the notice does not provide relief from penalties under Section 6707A(a) for participants required to file a copy of their disclosure statements with OTSA at the same time the participant first files a disclosure statement by attaching it to the participant’s tax return.
Taxpayers who are concerned about meeting the due date for these disclosure statements can ask for an extension of the due date for their tax return to obtain additional time to file such disclosure statements. The disclosures required from participants in micro-captive listed transactions and transactions of interest on or after July 31, 2025, remain due as otherwise set forth in the regulations.
There’s also a waiver for the material advisor penalty for similar reasons. “In light of potential challenges associated with preparing disclosure statements during tax return filing season and in the interest of sound tax administration, the IRS will waive penalties under section 6707(a) with 5 respect to Later Identified Micro-captive Listed Transaction and Later Identified Microcaptive Transaction of Interest disclosure statements completed in accordance with § 301.6111-3(d) and the instructions to Form 8918, Material Advisor Disclosure Statement, if the material advisor files the required disclosure statement with OTSA by July 31, 2025,” said the notice. “Disclosures required from material advisors with respect to Micro-captive Listed Transactions and Micro-captive Transactions of Interest on or after July 31, 2025, remain due as otherwise set forth in § 301.6111-3(e). This notice does not modify any list maintenance and furnishment obligations of material advisors as set forth in section 6112 and § 301.6112-1. “
In my work with accounting firms, I’ve lost count of how many times I’ve heard partners say some version of: “We’re paying top dollar. Why are people still leaving?” One conversation particularly sticks with me — a managing partner genuinely baffled by rising turnover despite offering excellent compensation packages.
What I often discover isn’t surprising: Many firms have mastered technical excellence and client service while leadership runs on autopilot. They focus almost exclusively on metrics and deadlines, forgetting the human element. No wonder talented professionals walk out the door seeking workplaces where they’re valued for more than just their billable hours.
Traditional accounting leadership has often prioritized technical excellence and client service at the expense of human connection. We’ve built cultures where being constantly available somehow equals commitment, boundaries are treated as limitations rather than assets, and professional development means technical improvement instead of leadership growth.
Technology has both connected and disconnected us. I’ve worked with firms where team members haven’t had a meaningful conversation with their managers in months despite being on Zoom calls together every day. This disconnect leads to declining engagement and stalled innovation, and makes retaining talented professionals increasingly difficult.
Connected leadership isn’t complicated — it’s about creating real relationships through intentional practices that build trust. It’s the opposite of the “manage by spreadsheet” approach that’s all too common in our profession.
I love thinking about connected leadership like conducting an orchestra. Great conductors don’t just keep time — they understand what makes each musician unique, create space for individual expression within the group, and know when certain sections should shine while others provide support. Most importantly, they get that beautiful music comes from relationships, not just technical precision.
This approach sits at the heart of what I teach through The B³ Method — Business + Balance = Bliss. When leaders create environments where team members feel genuinely seen and valued, magic happens — both in personal fulfillment and on the bottom line.
Alenavlad – stock.adobe.com
The business case for connection
Before dismissing this as too “soft” for our numbers-driven profession, consider the data. According to Gallup’s 2024 State of the Global Workplace report, low employee engagement costs the global economy $8.9 trillion annually — an extraordinary sum that affects businesses of all sizes.
Organizations with high engagement see 21% higher profitability and significantly lower turnover. What accounting leaders really need to understand is that managers account for 70% of the variance in team engagement. When managers themselves are engaged, employees are twice as likely to be engaged too. These positive shifts translate to better retention, stronger client relationships and improved profitability.
Beyond retention, connected leadership directly impacts client relationships and innovation. When team members feel psychologically safe, they’re more likely to raise concerns, suggest improvements, and deliver exceptional client service.
Becoming a connected leader
You don’t need to overhaul your entire firm to start seeing results. Try these practical approaches:
Take a beat. Before jumping into solutions or directives, pause to really listen. Some of my most successful clients start meetings with “connection before content” — spending just a few minutes establishing human connection before diving into the agenda. I recently had an attendee of my Connected Leadership workshop tell me: “Taking just two minutes to meditate can remarkably reset the nervous system, providing a quick and effective way to find calm and focus during a busy workday.”
Create boundary rituals. Work-life harmony isn’t about perfect balance — it’s about intentional integration. Help your team establish clear boundaries that actually enhance client service, like “no-meeting Fridays” or dedicated deep work blocks. One partner told me their key takeaway was “to take care of myself to be better in all aspects of life!”
Measure what matters. Beyond billable hours and realization rates, assess team connections through regular check-ins focused on engagement and belonging. Another workshop participant noted that, as a leader, they must take “100% responsibility for my own actions and outcomes.” What gets measured gets managed — so measure the human element, too.
Get comfortable with vulnerability. Share appropriate challenges and lessons learned, showing that vulnerability is a strength. Poignant feedback from my last workshop stated: “For the managing partners and leaders of the organization to put out there for us their vulnerabilities, past struggles, and pain is a testament to their humanity and endurance, and that is a powerful takeaway.”
The future of accounting leadership
Implementing connected leadership will likely face resistance, particularly in traditional accounting environments. This approach can initially be misperceived as “soft” or less important than technical skills. However, the firms that successfully navigate this transition recognize that connected leadership isn’t separate from business success — it’s foundational to it.
When faced with resistance, start small with measurable experiments. Document outcomes, adjust approaches and gradually expand successful practices. Focus on the business case rather than just the human case, though both are equally important.
As our profession navigates unprecedented talent challenges, we need to evolve how we lead. The firms that will thrive won’t just be those with the best technical expertise — they’ll be the ones where leaders prioritize connection alongside excellence.
I challenge you: Are you leading in a way that creates meaningful relationships, or are you perpetuating a culture where people feel like just another billable resource? Your answer might determine whether your firm struggles to keep talent or becomes a magnet for professionals seeking both success and fulfillment.
In an orchestra, the most powerful moments often come not from individual instruments playing louder, but from all sections playing in harmony. The same is true for our teams.
Ohio’s new law providing an alternative path to a CPA license has taken effect after 90 days and the Ohio Society of CPAs is pointing out another provision of the law, enabling out-of-state CPAs to practice in the Buckeye State.
Ohio Governor Mike DeWine signed House Bill 238 in January, enabling qualified CPAs from other states to work in Ohio, The OSCPA noted that other states are working to adopt similar language to Ohio.
“Automatic interstate mobility essentially works like a driver’s license,” said OSCPA president and CEO Laura Hay in a statement Thursday. “You can drive through our state without an Ohio license, but you still must follow our laws and if you don’t, you’re penalized. The same applies here – a licensed CPA in good standing can now practice here but must adhere to our strict professional standards.”
Four other states — Alabama, Nebraska, North Carolina and Nevada — currently function under this model. That means a CPA with a certificate in good standing issued by any other state is recognized and allowed practice privileges in those four states as well as Ohio. A number of states like Ohio are also taking steps to provide alternative pathways to CPA licensure aside from the traditional 150 credit hours. In addition, approximately half of all jurisdictions have indicated they are shifting to automatic mobility to ensure that CPAs from all states will have practice privileges and be under the jurisdiction of the state’s board of accountancy.
“The realities of globalization and virtualization place greater importance on the individual’s qualifications, rather than their place of licensure,” Hay stated. “And the more states we have that accept this model, the more successful we will all be in addressing the national CPA shortage.”
State CPA societies as well as the American Institute of CPAs and the National Association of State Boards of Accountancy have been working on ways to make the CPA license more accessible to expand the pipeline of young accountants coming into the profession and relieve the shortage.